One month from today, changes to how a CFI maintains their currency become effective. But what does this really mean for CFIs? The honest answer, not lots has changed and a CFI still needs to maintain their currency in mostly the same way they did before.
The main headline that you have likely seen so far is that “the CFI certificate no longer will have an expiration date on it.” That is true, but you have to carefully look at what that means. It means the physical plastic FAA certificate won’t have an expiration date; they won’t be sending new ones of these every time you renew your CFI currency like in the past. This does not however mean that your CFI “currency” does not expire anymore.
The main point of this change was to get the FAA out of the business of printing the physical plastic cards every two years; not to alleviate CFIs from the requirement of maintaining their knowledge and currency to act as a CFI through some sort of proficiency.
This becomes a “currency” of the CFI certificate privileges, instead of expiration of the actual CFI certificate. This means a CFI will need to track, document, and maintain their CFI currency just as they have done in the past to remain eligible to provide CFI instructional actions.
Let’s hit a couple of the main bullet points you should be aware of and not confused on so you don’t find yourself with expired CFI certificate privileges:
CFIs must still maintain currency as they have in the past
A CFI is still required to maintain currency every 24 calendar months through activities such as a Flight Instructor Refresher Course (FIRC), active instruction currency, or an alternate method of CFI proficiency demonstration such as using the FAA Wings Program (under specific requirements). There are a couple other ways, but the CFI must still do this every 24-calendar months or their CFI privileges will expire.
A CFI must still document their CFI currency through an 8710 form
When a CFI extends or reinstates their currency for another 24-calendar months, they must still submit an 8710 application and have it validated by an certifying official. So, when you renew your CFI currency, you will still need to provide an application (typically in IACRA) for CFI renewal that will be processed by an FAA ASI, a DPE who has Flight Instructor Renewal Examiner (FIRE) privileges, or an Airman’s Certification Representative (ACR).
This currency will continue to be represented in the FAA’s Airman Registry that can be queried online if a CFI or any students have any question regarding the active currency of any CFI providing training.
Reinstatement is Required if the CFI Currency Expires
If a CFI’s currency expires, they will still be required to complete a “CFI reinstatement practical test” or could also choose to add another CFI privilege to reinstate the CFI privileges. This is not any different than has been the case in the past.
The CFI reinstatement practical test, if needed, content is still driven by the task table in the CFI Airman Certification Standards.
“Reinstatement” via FIRC Grace Period [NEW]
There is one new caveat here, a “grace period” for reinstatement is now available. If your CFI currency expires, you have a three-month window in which you can “reinstate” the CFI currency using a FIRC. I anticipate that an application at this point would require the CFI to indicate “reinstatement” instead of “renewal”, but this offers the CFI who missed their renewal window a short period of time after which they can still reinstate the CFI privileges without having to go through a full “CFI reinstatement practical test.”
During the grace period, the CFI official has CFI privileges that are no longer current and is not able to exercise CFI privileges until a reinstatement has been completed.
What this might look like in practical application would be if a CFI expired on December 31 for their currency, they could do a FIRC and reinstate their CFI privileges in January, February, or March using a FIRC. If they go beyond that date, they would then need to do a practical test for reinstatement or add a new CFI privilege to reinstate the privileges.
There is a lot of confusion out there on this regulation change, so I wanted to help distill this down to a few key points that apply to most CFIs. The gist, for most CFIs, they will do the same things they have been doing to maintain their CFI certificate privileges, they just won’t bet getting a new CFI certificate in the mail every time they do it.
If you want to dig more into the details of this particular change, check out the AOPA CFI Removal Regulation FAQ by clicking here.
Or, if you really want to dig deep, you can find the final FAA rule that was published by clicking here.
I hope this helps all all of you out there with understanding the rule change and please help us make sure all our fellow CFIs understand it to avoid them expiring! Or worse, ending up providing unauthorized training to students!